Privacy policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The Privacy Policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as the “Online Offer”).

The terms used are not gender-specific.

Last updated: 5 December 2024

Table of contents

Person in charge

Sulejman Dallashaj

E-mail address: anfrage@sg-watches.de

Overview of processing The

following overview summarizes the types of data processed and the purposes of their processing, and refers to the data subjects.

Types of data processed

  • Inventory data.
  • Payment.
  • Location.
  • Contact details.
  • Content Data.
  • Contract.
  • Usage.
  • Meta, communication and procedural data.
  • Event data (Facebook).
  • Log.

Categories of data subjects

  • Service recipients and clients.
  • Interested parties.
  • Communication.
  • User.
  • Business and contractual partners.
  • Customers.

Purposes of processing

  • Provision of contractual services and fulfilment of contractual obligations.
  • Communication.
  • Security Measures.
  • Direct marketing.
  • Range measurement.
  • Tracking.
  • Office and organizational procedures.
  • Conversion measurement.
  • Target group formation.
  • Organisational and administrative procedures.
  • Feedback.
  • Marketing.
  • User-related information profiles.
  • Provision of our online offer and user-friendliness.
  • Information technology infrastructure.
  • Public relations.
  • Sales promotion.
  • Business processes and business procedures.

Relevant legal bases

Relevant legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or purposes.
  • Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) – the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that the interests, fundamental rights and freedoms of the data subject which require the protection of personal data are not overridden.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special provisions on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. In addition, state data protection laws of the individual federal states can be applied.

Note on the applicability of the GDPR and the Swiss FADP: This data protection notice serves both the provision of information in accordance with the Swiss Data Protection Act and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “particularly sensitive personal data” used in the Swiss FADP, the terms “processing” of “personal data” as well as “legitimate interest” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss FADP within the scope of the Swiss FADP.

Safety measures

In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

Measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, availability and separation. We have also put in place procedures to ensure that the rights of data subjects are exercised, that data is deleted and that data is compromised. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, through technical design and through data protection-friendly default settings.

Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as “IP masking”). The last two digits, or the last part of the IP address after a period, are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or significantly complicate the identification of a person on the basis of his or her IP address.

Securing online connections with TLS/SSL encryption technology (HTTPS): In order to protect the data of users transmitted via our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), which protects the data from unauthorized access. TLS, as the evolved and more secure version of SSL, ensures that all data transfers meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator for users that their data is being transmitted securely and encrypted.

Transfer of personal data

As part of our processing of personal data, it may be transmitted to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data transfers within the organization: We may transfer personal information to or provide access to other departments or entities within our organization. If the data is passed on for administrative purposes, it is based on our legitimate business and business interests or if it is necessary for the fulfilment of our contractual obligations or if the consent of the data subjects or a legal permission has been obtained.

International data transfers

Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements. If the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is otherwise ensured, in particular by means of standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), explicit consent or in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis of the third-country transfer for the individual providers from the third country, with the adequacy decisions taking precedence as the basis. Information on third-country transfers and existing adequacy decisions can be found in the EU Commission’s information service: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de. As part of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection as secure for certain companies from the USA as part of the adequacy decision of 10.07.2023. The list of certified companies as well as further information about the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ . As part of the data protection notice, we will inform you which service providers we use are certified under the Data Privacy Framework.

General information on data storage and deletion

We delete personal data that we process in accordance with the law, as soon as the underlying consents are withdrawn or there are no other legal grounds for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer needed. Exceptions to this regulation exist if legal obligations or special interests require longer storage or archiving of the data.

In particular, data that must be retained for commercial or tax reasons, or the storage of which is necessary for legal prosecution or to protect the rights of other natural or legal persons, must be archived accordingly.

Our Privacy Notice contains additional information on the retention and deletion of data that applies specifically to certain processing operations.

If there is more information about the retention period or deletion periods of a date, the longest period is always decisive.

If a time limit does not expressly begin on a specific date and is at least one year, it shall automatically start at the end of the calendar year in which the event triggering the time limit occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the time when the termination or other termination of the legal relationship takes effect.

We process data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, exclusively for the reasons that justify its storage.

Further information on processing processes, procedures and services:

  • Retention and deletion of data: The following general deadlines apply to retention and archiving under German law:
    • 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the work instructions and other organisational documents, accounting documents and invoices required for their understanding (sec. 147 para. 3 in conjunction with para. 1 nos. 1, 4 and 4a AO, sec. 14b para. 1 UStG, sec. 257 para. 1 nos. 1 and 4, para. 4 HGB).
    • 6 years – Other business documents: received commercial or business letters, reproductions of the commercial or business letters sent, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, company accounting sheets, calculation documents, price labelling, but also payroll documents, insofar as they are not already accounting documents and cash strips (§ 147 para. 3 in conjunction with para. 1 nos. 2, 3, 5 AO, § 257 para. 1 nos. 2 and 3, para. 4 HGB).
    • 3 years – Data necessary to consider potential warranty and indemnity claims or similar contractual claims and rights, as well as to process related requests, based on previous business experience and common industry practices, will be retained for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of data subjects

Rights of data subjects under the GDPR: As data subjects, you have various rights under the GDPR, which result in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you that is carried out on the basis of Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is related to such direct advertising.
  • Right of revocation in the case of consent: You have the right to revoke any consent you have given at any time.
  • Right: You have the right to request confirmation as to whether the data in question is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately, or alternatively to demand a restriction of the processing of the data in accordance with the legal requirements.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
  • Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the requirements of the GDPR.

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”), in the context of contractual and comparable legal relationships as well as related measures and with regard to communication with the contractual partners (or pre-contractually), for example to answer inquiries.

We use this data to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedy in the event of warranty and other service disruptions. In addition, we use the data to protect our rights and for the purpose of the administrative tasks associated with these obligations as well as the company organization. In addition, we process the data on the basis of our legitimate interests both in proper and business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the scope of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations. The contractual partners are informed about other forms of processing, such as for marketing purposes, within the framework of this data protection declaration.

We inform the contractual partners of which data is required for the aforementioned purposes before or as part of the data collection, e.g. in online forms, by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or personally.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal reasons of archiving (e.g. for tax purposes, usually ten years). We delete data that has been disclosed to us by the contractual partner in the context of an order in accordance with the specifications and in principle after the end of the order.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact details (e.g. postal and email addresses or telephone numbers); Contract data (e.g. subject matter of the contract, term, customer category); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). Metalogical, communication and procedural data (e.g. IP addresses, times, identification numbers, persons involved).
  • Data subjects: Service recipients and clients; Interested parties. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; Security measures; Communication; Office and organizational procedures; Organisational and administrative procedures. Business processes and business procedures.
  • Retention and deletion: Deletion as indicated in the section “General information on data storage and deletion”.
  • Legal bases: Performance of the contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

  • Online shop, order forms, e-commerce and delivery: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as to pay for them and deliver them. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery, provision and invoicing, as well as contact information in order to be able to consult with us if necessary; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Business Processes and Procedures

Personal data of service recipients and clients – including customers, clients or, in special cases, clients, patients or business partners as well as other third parties – are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting and project management.

The data collected is used to fulfill contractual obligations and to make operational processes efficient. This includes handling business transactions, managing customer relationships, optimizing sales strategies, and ensuring internal invoicing and financial processes. In addition, the data supports the protection of the rights of the controller and promotes administrative tasks as well as the organization of the company.

Personal data may be disclosed to third parties if this is necessary to fulfil the aforementioned purposes or legal obligations.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number)
  • Payment data (e.g. bank details, invoices, payment history –
  • Contact details (e.g. postal and email addresses)
  • Content data (e.g., textual or pictorial news and posts, and information about them, such as authorship information)
  • Contract data (e.g. subject matter of the contract, term, customer category
  • Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions
  • Meta, communication and procedural data (e.g. IP addresses, times, identification numbers)
  • Data subjects: Service recipients and clients; Interested parties; Communication; Business and contractual partners. Customers.
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; Office and organizational procedures; business processes and business procedures; Security Measures. Provision of our online offer and user-friendliness.
  • Retention and deletion: Deletion as indicated in the section “General information on data storage and deletion”.
  • Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

  • Account: Customers can create an account within our online offer (e.g. customer or user account, or “customer account” for short). If the registration of a customer account is required, customers will be informed of this as well as the information required for registration. The customer accounts are not public and cannot be indexed by search engines. As part of the registration as well as subsequent logins and use of the customer account, we store the IP addresses of the customers along with the access times in order to be able to prove registration and prevent any misuse of the customer account. If the customer account has been terminated, the customer account data will be deleted after the date of termination, unless it is retained for purposes other than making it available in the customer account or must be retained for legal reasons (e.g. internal storage of customer data, order processes or invoices). It is the responsibility of the customers to secure their data when the customer account is terminated; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Economic analysis and market research: In order to fulfil business purposes and to identify market trends, the wishes of contractual partners and users, the available data on business transactions, contracts, enquiries, etc. are analysed. The group of data subjects may include contractual partners, interested parties, customers, visitors and users of the controller’s online offer. The analysis is carried out for the purposes of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). If available, profiles of registered users are taken into account, along with their details of services used. The analyses are for the sole purpose of the controller and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymised values. In addition, the privacy of the users is taken into account; the data is processed for analysis purposes in a pseudonymized manner and, where possible, anonymized (e.g. as aggregated data); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Payment

In the context of contractual and other legal relationships, on the basis of legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions (collectively “payment service providers”).

The data processed by the payment service providers includes inventory data, such as name and address, bank data such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient-related information. The information is required to carry out the transactions. However, the data entered will only be processed by and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information confirming or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transfer is to check identity and creditworthiness. For this purpose, we refer to the terms and conditions and the data protection information of the payment service providers.

The terms and conditions and data protection notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications, apply to the payment transactions. We also refer to them for the purpose of further information and assertion of rights of revocation, information and other data subjects.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject matter of the contract, term, customer category); Usage Data (e.g., page views and dwell time, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and features); Metalogical, communication and procedural data (e.g. IP addresses, times, identification numbers, persons involved). Contact details (e.g. postal and email addresses or telephone numbers).
  • Data subjects: Service recipients and clients; Business and contractual partners. Interested parties.
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Business processes and business procedures.
  • Retention and deletion: Deletion as indicated in the section “General information on data storage and deletion”.
  • Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

  • Apple Pay: Payment services (technical connection of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.apple.com/de/apple-pay/. Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
  • Giropay: Payment services (technical connection of online payment methods); Service provider: giropay GmbH, An der Welle 4, 60322 Frankfurt, Germany; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.giropay.de. Privacy Policy: https://www.giropay.de/rechtliches/datenschutzerklaerung/.
  • Google Pay: Payment services (technical connection of online payment methods); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://pay.google.com/intl/de_de/about/. Privacy Policy: https://policies.google.com/privacy.
  • Klarna: Payment services (technical connection of online payment methods); Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.klarna.com/de. Privacy Policy: https://www.klarna.com/de/datenschutz.
  • Mastercard: Payment services (technical connection of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.mastercard.de/de-de.html. Privacy Policy: https://www.mastercard.de/de-de/datenschutz.html.
  • PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.paypal.com/de. Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
  • Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://stripe.com; Privacy Policy: https://stripe.com/de/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).
  • Visas: Payment services (technical connection of online payment methods); Service provider: Visa Europe Services Inc., London Branch, 1 Sheldon Square, London W2 6TT, UK; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.visa.de; Privacy Policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html. Basis for third-country transfers: Adequacy Decision (GB).

Provision of the online offer and web hosting

We process users’ data in order to be able to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device.

  • Types of data processed: Usage Data (e.g., page views and dwell time, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and features); Metalogical, communication and procedural data (e.g. IP addresses, times, identification numbers, persons involved). Log data (e.g. log files regarding logins or the retrieval of data or access times.).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security Measures.
  • Retention and deletion: Deletion as indicated in the section “General information on data storage and deletion”.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

  • Collection of access data and log files: Access to our online offer is logged in the form of so-called “server log files”. The server log files can include the address and name of the websites and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and to ensure the load on the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
  • Hetzner: services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: 25, 91710 Gunzenhausen, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.hetzner.com; Privacy Policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data Processing Agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.

Use of cookies

The term “cookies” refers to functions that store information on and read information from users’ devices. Cookies can also be used in relation to various concerns, such as for the purposes of the functionality, security and convenience of online offers as well as the creation of analyses of visitor flows. We use cookies in accordance with the law. To do this, we obtain the consent of the users in advance, if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and reading of information is essential in order to be able to provide explicitly requested content and functions. This includes, for example, the storage of settings and the assurance of the functionality and security of our online offer. Consent can be revoked at any time. We provide clear information about their scope and which cookies are used.

Information on data protection legal bases: Whether we process personal data using cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the relevant services and procedures.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their device (e.g. browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the device is closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. as part of obtaining consent), they should assume that they are permanent and that they can be stored for up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also declare an objection to the processing in accordance with the legal requirements, also by means of the privacy settings of their browser.

  • Types of data processed: Metalogical, communication and procedural data (e.g. IP addresses, times, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing processes, procedures and services:

  • Processing of cookie data on the basis of consent: We use a consent management solution that obtains users’ consent to the use of cookies or to the procedures and providers specified in the consent management solution. This procedure serves to obtain, record, manage and revoke consent, in particular with regard to the use of cookies and similar technologies used to store, read and process information on users’ end devices. As part of this process, users’ consents are obtained for the use of cookies and the related processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and withdrawing their consents. The declarations of consent are stored in order to avoid a new query and to be able to provide proof of consent in accordance with the legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or his device. Unless specific information is available on the providers of consent management services, the following general information applies: The duration of the storage of consent is up to two years. This involves the creation of a pseudonymous user identifier that is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers), as well as information about the browser, the system and the device used; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
  • BorlabsCookie: Consent management: procedures for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users’ end devices as well as their processing; Service provider: Execution on servers and/or computers under its own responsibility under data protection law; Website: https://de.borlabs.io/borlabs-cookie/. Further information: An individual user ID, language, as well as types of consents and the time of their submission are stored on the server side and in the cookie on the user’s device.

Contact and request management

When contacting us (e.g. by post, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the enquiring persons will be processed insofar as this is necessary to answer the contact requests and any requested measures.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); Contact details (e.g. postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial news and posts, and information about them, such as authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). Metalogical, communication and procedural data (e.g. IP addresses, times, identification numbers, persons involved).
  • Data subjects: Communication.
  • Purposes of processing: Communication; organisational and administrative procedures; Feedback (e.g. collecting feedback via online form). Provision of our online offer and user-friendliness.
  • Retention and deletion: Deletion as indicated in the section “General information on data storage and deletion”.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing processes, procedures and services:

  • Contact: If you contact us via our contact form, by e-mail or other means of communication, we process the personal data transmitted to us in order to answer and process the respective request. This usually includes details such as name, contact information and, where applicable, other information that is shared with us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of contacting and communicating; Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Communication via Messenger

We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, encryption, the use of the metadata of the communication and your objection options.

You can also contact us by alternative means, e.g. by phone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer.

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of Messenger with encryption enabled to ensure that message content is encrypted.

However, we would also like to point out to our communication partners that although the providers of the messengers do not view the content, they can find out that and when communication partners communicate with us and that technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) is processed.

Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. In addition, if we do not ask for consent and you contact us on your own initiative, for example, we use Messenger as a contractual measure in relation to our contractual partners as well as in the context of the initiation of a contract and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and fulfilment of the needs of our communication partners in communication via Messenger. Furthermore, we would like to point out that we will not transmit the contact details provided to us to the messengers for the first time without your consent.

Revocation, objection and deletion: You can revoke your consent at any time.

  • Types of data processed: Contact details (e.g. postal and e-mail addresses
    • ) Data
  • subjects: Communication partners.
  • Purposes of processing: Communication.
  • Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Chatbots and chat features

We offer online chats and chatbot features as a means of communication (collectively, “Chat Services”). A chat is an online conversation that is conducted with a certain degree of timeliness. A chatbot is software that answers users’ questions or informs them about messages. When you use our chat features, we may process your personal data.

If you use our chat services within an online platform, your identification number will also be stored within the respective platform. We may also collect information about which users interact with our chat services and when. We also store the content of your conversations via the chat services and log registration and consent processes in order to be able to prove them in accordance with legal requirements.

We would like to point out to users that the respective platform provider may find out that and when users communicate with our chat services, as well as collect technical information about the user’s device and, depending on the settings of their device, also location information (so-called metadata) for the purposes of optimizing the respective services and security purposes. Similarly, the metadata of communication via chat services (i.e., e.g., information about who communicated with whom) may be used by the respective platform providers for marketing purposes or to display advertising tailored to users in accordance with their policies, to which we refer for further information.

If users agree to a chatbot to activate information with regular messages, they have the option of unsubscribing from the information for the future at any time. The chatbot points out to users how and with which terms they can unsubscribe from the messages. By unsubscribing from chatbot messages, user data is deleted from the directory of message recipients.

We use the above information to operate our chat services, e.g. to address users personally, to answer their requests, to transmit any requested content and also to improve our chat services (e.g. to “teach” chatbots answers to frequently asked questions

  • Types of data processed: Contact data (e.g. postal and e-mail addresses
    • )
  • Content data (e.g. textual or pictorial messages and posts as well as the information relating to them, such as information on authorship –
  • Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, types of devices and operating systems used, interactions
  • Purposes of processing: Communication.
  • Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter referred to as “newsletters”) exclusively with the consent of the recipients or on a legal basis. If the content of the newsletter is mentioned as part of a registration, this content is decisive for the consent of the user. To subscribe to our newsletter, it is usually sufficient to enter your e-mail address. However, in order to be able to offer you a personalized service, we may ask you to provide your name for a personal address in the newsletter or for further information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a potential defence against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blacklist (so-called “blocklist”) for this purpose alone.

The registration process is recorded on the basis of our legitimate interests for the purpose of proving that it is running properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.

Contents:

Information about us, our services, promotions and offers.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); Contact details (e.g. postal and email addresses or telephone numbers); Metalogical, communication and procedural data (e.g. IP addresses, times, identification numbers, persons involved). Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features).
  • Data subjects: Communication. Users (e.g., website visitors, users of online services).
  • Purposes of processing: Direct marketing (e.g. by email or post). Provision of contractual services and fulfilment of contractual obligations.
  • Legal bases: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
  • Opt-out: You can unsubscribe from receiving our newsletter at any time, i.e. . h. Withdraw your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.

Further information on processing processes, procedures and services:

  • Measurement of open and click-through rates: The newsletters contain a so-called “web beacons”, i.e. a pixel-sized file that is retrieved from our or its server when the newsletter is opened, if we use a shipping service provider. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval are initially collected. This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their access locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The evaluations are used to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of opening and click rates as well as the storage of the measurement results in the profiles of the users Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
  • Prerequisite for the use of free services: Consent to the sending of mailings can be made conditional as a prerequisite for the use of free services (e.g. access to certain content or participation in certain promotions). If users would like to take advantage of the free service without registering for the newsletter, please contact us.
  • Sending via SMS: The electronic notifications may also be sent as SMS text messages (or will be sent exclusively via SMS if the authorisation to send, e.g. consent, only includes sending via SMS); Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Advertising communication via e-mail, post, fax or telephone

We process personal data for the purposes of advertising communication, which can be carried out via various channels, such as e-mail, telephone, post or fax, in accordance with the legal requirements.

Recipients have the right to revoke their consent at any time or to object to advertising communications at any time.

After revocation or objection, we store the data required to prove the previous authorisation for contacting or sending you data for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the users, we also store the data necessary to avoid renewed contact (e.g. e-mail address, telephone number, name, depending on the communication channel).

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); Contact details (e.g. postal and email addresses or telephone numbers). Content data (e.g., textual or pictorial messages and posts, and information about them, such as authorship or time of creation).
  • Data subjects: Communication partners.
  • Purposes of processing: direct marketing (e.g. by e-mail or post); Marketing. Sales promotion.
  • Retention and deletion: Deletion as specified in the section “General information on data storage and deletion”.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Web analysis, monitoring and optimization

Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offer and can include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, see at what time our online offer or its functions or content are used most often, or invite them to reuse. It is also possible for us to understand which areas need optimization.

In addition to web analysis, we may also use test procedures to test and optimize different versions of our online offer or its components.

Unless otherwise stated below, profiles, i.e. data combined into a usage process, may be created for these purposes and information may be stored in a browser or in an end device and then read. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used and information on times of use. If users have consented to the collection of their location data vis-à-vis us or the providers of the services we use, the processing of location data is also possible.

In addition, the IP addresses of the users are stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, the user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). Metalogical, communication and procedural data (e.g. IP addresses, times, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creating user profiles). Provision of our online offer and user-friendliness.
  • Retention and deletion: Deletion as indicated in the section “General information on data storage and deletion”. Storing cookies for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Safety Measures: IP masking (pseudonymization of the IP address).
  • Legal bases: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

  • Google Analytics: We use Google Analytics to measure and analyze the use of our online offer on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to a terminal device in order to identify which content users have accessed within one or more usage processes, which search terms they have used, accessed again or interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offer and technical aspects of their devices and browsers.
    Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: city (and the city’s inferred latitude and longitude), continent, country, region, subcontinent (and ID-based counterparts). In the case of EU data traffic, the IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. They are not logged, are not accessible and are not used for other purposes. When Google Analytics collects metrics, all IP queries are performed on EU-based servers before traffic is routed to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Safety Measures: IP masking (pseudonymization of the IP address); Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF); Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and data processed).
  • Google Tag Manager: We use Google Tag Manager, a software from Google that allows us to manage so-called website tags centrally via a user interface. Tags are small pieces of code on our website that are used to record and analyze visitor activity. This technology helps us to improve our website and the content offered on it. The Google Tag Manager itself does not create user profiles, does not store cookies with user profiles and does not perform independent analyses. Its function is limited to simplifying and making it more efficient to integrate and manage the tools and services we use on our website. Nevertheless, when using Google Tag Manager, the IP address of the users is transmitted to Google, which is necessary for technical reasons to implement the services we use. Cookies can also be set. However, this data processing only takes place if services are integrated via the Tag Manager. For more detailed information on these services and their data processing, please refer to the further sections of this privacy policy; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement:
    https://business.safety.google/adsprocessorterms. Basis for third-country transfers: Data Privacy Framework (DPF).

Online marketing

We process personal data for the purpose of online marketing, which may include, in particular, the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (the so-called “cookie”) or similar processes are used to store the information about the user relevant to the presentation of the aforementioned content. This may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used, as well as information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.

In addition, the IP addresses of the users are stored. However, we use available IP masking methods (i.e. pseudonymization by shortening the IP address) for user protection. In general, no clear data of the users (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing methods, do not know the actual user identity, but only the information stored in their profiles.

The statements in the profiles are usually stored in the cookies or by similar methods. These cookies can later be read out on other websites that use the same online marketing process and analysed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, it is possible to assign clear data to the profiles, primarily if the users are members of a social network whose online marketing methods we use and the network connects the user profiles with the aforementioned information. We ask you to note that users can make additional agreements with the providers, for example by giving consent as part of the registration process.

As a matter of principle, we only have access to aggregated information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us, for example. Conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.

Notes on legal bases: If we ask the users for their consent to the use of the third-party providers, the legal basis for the data processing is the permission. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Notes on revocation and objection:

We refer to the data protection information of the respective providers and the objection options specified for the providers (so-called “opt-out”). Unless an explicit opt-out option has been specified, there is the possibility that you switch off cookies in the settings of your browser. However, this may limit the functions of our online offer. We therefore also recommend the following opt-out options, which are offered collectively for the respective areas:

a) Europe: https://www.youronlinechoices.eu.

b) Canada: https://www.youradchoices.ca/choices.

c) USA: https://www.aboutads.info/choices.

d) Cross-territorial: https://optout.aboutads.info.

  • Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). Metalogical, communication and procedural data (e.g. IP addresses, times, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); Tracking (e.g., interest/behavioral profiling, use of cookies); target group formation; Marketing; Profiles with user-related information (creating user profiles). Conversion measurement (measuring the effectiveness of marketing measures).
  • Retention and deletion: Deletion as indicated in the section “General information on data storage and deletion”. Storing cookies for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Safety Measures: IP masking (pseudonymization of the IP address).
  • Legal bases: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

  • Google Ads and Conversion Measurement: Online marketing procedures for the purpose of placing content and advertisements within the service provider’s advertising network (e.g. in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the advertisements. In addition, we measure the conversion of the ads, i.e. whether users have taken them as an opportunity to interact with the ads and take advantage of the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms.

Customer reviews and evaluation procedures

We participate in review and evaluation processes to evaluate, optimize and promote our services. If users rate us or otherwise provide feedback via the review platforms or procedures involved, the general terms and conditions of use and the data protection notices of the providers also apply. As a rule, the evaluation also requires registration with the respective providers.

In order to ensure that the reviewers have actually used our services, we transmit the necessary data with regard to the customer and the service used to the respective review platform (including name, e-mail address and order number or article number) with the consent of the customers. This data is used solely to verify the authenticity of the user.

  • Types of data processed: Contract data (e.g. subject matter of the contract, term, customer category); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features).
  • Data subjects: Service recipients and clients. Users (e.g., website visitors, users of online services).
  • Purposes of processing: Feedback (e.g. collecting feedback via online form). Marketing.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

We would like to point out that user data may be processed outside the area of the European Union. This can result in risks for users, for example, because it could make it more difficult to enforce user rights.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the user behavior and the resulting interests of the users. The latter may in turn be used, for example, to place advertisements inside and outside the networks that presumably correspond to the interests of the users. Therefore, cookies are usually stored on the users’ computers, in which the user’s usage behaviour and interests are stored. In addition, data can also be stored in the user profiles regardless of the devices used by the users (in particular if they are members of the respective platforms and logged in there).

For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can directly take appropriate measures and provide information. If you still need help, you can contact us.

  • Types of data processed: Contact details (e.g. postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and posts, and information about them, such as authorship or time of creation). Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Communication; Feedback (e.g. collecting feedback via online form). Public relations.
  • Retention and deletion: Deletion as indicated in the section “General information on data storage and deletion”.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

  • Instagram: Social network, allows you to share photos and videos, comment and favorite posts, send messages, subscribe to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).
  • Facebook pages: Profiles within the social network Facebook – Together with Meta Platforms Ireland Limited, we are responsible for the collection (but not the further processing) of data of visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see “Things You and Others Do and Provide” in Facebook’s Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language preferences, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in Facebook’s Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services called “Page Insights” to Page operators to provide them with insights into how people interact with their Pages and with the content associated with them. We have concluded a special agreement with Facebook (“Page Insights Information”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to comply with the rights of data subjects (i.e. users can, for example, direct information or deletion requests to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “About Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data). Joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular with regard to the transfer of the data to the parent company Meta Platforms, Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).
  • Pinterest: Social network, allows you to share photos, comment, favorite and curate posts, send messages, subscribe to profiles; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.pinterest.com. Privacy Policy: https://policy.pinterest.com/de/privacy-policy.
  • X: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://x.com. Privacy Policy: https://x.com/de/privacy.
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Opt-out: https://myadcenter.google.com/personalizationoff.
  • Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.xing.com/. Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.

Plug-ins and embedded functions and content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This can be, for example, graphics, videos or city maps (hereinafter referred to uniformly as “content”).

The integration always requires that the third-party providers of this content process the IP address of the users, as they would not be able to send the content to their browser without an IP address. The IP address is therefore required for the display of these contents or functions. We make every effort to use only content whose respective providers use the IP address only for the delivery of the content. Third-party service providers may also use pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information, such as visitor traffic to the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information on the browser and operating system, referring websites, the time of visit and other information on the use of our online offer, but may also be combined with such information from other sources.

Notes on legal bases: If we ask the users for their consent to the use of the third-party providers, the legal basis for the data processing is the permission. Otherwise, the user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage Data (e.g., page views and dwell time, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and features); Metalogical, communication and procedural data (e.g. IP addresses, time details, identification numbers, persons involved); Inventory data (e.g., full name, home address, contact information, customer number, etc.); Contact details (e.g. postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial news and posts, and information about them, such as authorship or time of creation); Location data (information about the geographical location of a device or person). Event data (Facebook) (“Event data” is information that is sent to the provider Meta, for example, via meta-pixels (whether via apps or other channels) and refers to people or their actions. This data includes details about website visits, interactions with content and features, app installs, and product purchases. The event data is processed with the aim of creating target groups for content and advertising messages (Custom Audiences). It’s important to note that event data doesn’t include actual content like written comments, login information, and contact information like names, email addresses, or phone numbers. “Event data” will be deleted by Meta after a maximum of two years, and the resulting audiences will disappear with the deletion of our Meta user accounts.).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; Marketing. Profiles with user-related information (creating user profiles).
  • Retention and deletion: Deletion as indicated in the section “General information on data storage and deletion”. Storing cookies for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Legal bases: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

  • Facebook plugins and content: Facebook social plugins and content – This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within Facebook. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – We are jointly with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of “event data” that Facebook collects by means of the Facebook social plugins (and embedding functions for content) that are carried out on our online offer or in the context of a transmission to is jointly responsible for the following purposes: a) display content and advertising information that correspond to the presumed interests of the users; b) delivery of commercial and transactional messages (e.g. addressing users via Facebook Messenger); c) Improving ad delivery and personalization of features and content (e.g., improving the recognition of what content or advertising information is likely to be relevant to users’ interests). We have concluded a special agreement with Facebook (“Addendum for Controllers”, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to comply with the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not contain information about individual users and are anonymous to us), then this processing is not carried out under joint responsibility, but on the basis of a data processing agreement (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing) , the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms) as well as with regard to processing in the USA on the basis of standard contractual clauses (“Facebook-EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).
  • Google Fonts (provided on your own server): Provision of font files for the purpose of a user-friendly presentation of our online offer; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Google Fonts (obtained from Google Server): Procurement of fonts (and symbols) for the purpose of a technically safe, maintenance-free and efficient use of fonts and symbols with regard to topicality and loading times, their uniform presentation and consideration of possible licensing restrictions. The provider of the fonts is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted that are necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA – When visiting our online offer, the users’ browsers send their browsers HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) of Google Fonts and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the user to access the Internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user-agent that describes the browser and operating system versions of the website visitors, and the referral URL (i.e., the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and they are not analyzed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user-agent, and referral URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user-agent has to customize the font that is generated for the respective browser type. The user-agent is logged primarily for debugging and is used to generate aggregated usage statistics that are used to measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts Analytics page. Finally, the referral URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations can be generated based on the number of font requests. Google says it does not use any of the information collected by Google Fonts to profile end users or serve targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
  • Google Maps: We integrate the maps of the “Google Maps” service of the provider Google. The data processed may include, in particular, IP addresses and location data of users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://mapsplatform.google.com/; Privacy Policy: https://policies.google.com/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).
  • Instagram plugins and content: Instagram plugins and content – This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within Instagram. – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not further processing) of “Event Data” that Facebook collects through Instagram features (e.g. embedding functions for content) performed on our Online Offer or receives in the context of a transmission for the following purposes: a) Display of content and advertising information, that correspond to the presumed interests of the users; b) delivery of commercial and transactional messages (e.g. addressing users via Facebook Messenger); c) Improving ad delivery and personalization of features and content (e.g., improving the recognition of what content or advertising information is likely to be relevant to users’ interests). We have concluded a special agreement with Facebook (“Addendum for Controllers”, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to comply with the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not receive information about individual users and are anonymous to us), then this processing is not carried out under joint responsibility, but on the basis of a data processing agreement (‘Data Processing Terms’, https://www.facebook.com/legal/terms/dataprocessing) , the ‘Data Security Terms’ (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the USA on the basis of standard contractual clauses (“Facebook-EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com. Privacy Policy: https://privacycenter.instagram.com/policy/.
  • Pinterest plugins and content: Pinterest plugins and content – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online offering within Pinterest; Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.pinterest.com. Privacy Policy: https://policy.pinterest.com/de/privacy-policy.
  • YouTube videos: Video; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
  • YouTube videos: Video; YouTube videos are integrated via a special domain (recognizable by the component “youtube-nocookie”) in the so-called “extended data protection mode”, which means that no cookies are collected on user activities in order to personalize video playback. Nevertheless, information about the interaction of users with the video (e.g. remembering the last playback point) can be stored; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).

Modification and updating

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as the changes in the data processing we carry out make it necessary. We will inform you as soon as the changes require you to cooperate (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Definitions

This section provides an overview of the terminology used in this Privacy Policy. Insofar as the terms are defined by law, their legal definitions shall apply. The following explanations, on the other hand, are primarily intended to serve understanding.

  • Inventory data: Inventory data includes essential information necessary for the identification and management of contractors, user accounts, profiles, and similar assignments. This data may include, but is not limited to, personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between people and services, facilities, or systems by enabling unambiguous mapping and communication.
  • Content data: Content data includes information generated in the course of creating, editing, and publishing content of all kinds. This category of data may include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates
  • Contact details: Contact details are essential information that enables communication with individuals or organizations. They include, but are not limited to, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
  • Conversion measurement: Conversion measurement (also known as “visit action evaluation”) is a method that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, it allows us to understand whether the ads we have placed on other websites have been successful.
  • Meta-, communication and procedural data: Meta, communication, and procedural data are categories that contain information about the way in which data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. They can include information about the file size, the date it was created, the author of a document, and the change histories. Communication data captures the exchange of information between users through various channels, such as email traffic, call logs, social media messages, and chat histories, including the people involved, time stamps, and transmission routes. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review operations.
  • Usage: Usage Data refers to information that captures how users interact with digital products, services, or platforms. This data includes a wide range of information that reveals how users use applications, what features they prefer, how long they spend on certain pages, and what paths they use to navigate through an application. Usage Data may also include frequency of use, timestamps of activity, IP addresses, device information, and location data. They are especially valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and possible problem areas within digital offerings
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “user-related information profiles”, or “profiles” for short, includes any form of automated processing of personal data consisting of the use of such personal data in order to obtain certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behaviour and interests, such as interaction with websites and their content, etc.) Analyze, evaluate, or predict them (e.g., interests in certain content or products, click behavior on a web page, or location). Cookies and web beacons are often used for profiling purposes.
  • Log: Log data is information about events or activities that have been logged on a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system issues, monitor security, or generate performance reports.
  • Range measurement: Reach measurement (also known as web analytics) is used to evaluate the visitor flows of an online offer and can include the behavior or interests of visitors in certain information, such as content of websites. With the help of the reach analysis, operators of online services can identify, for example, at what time users visit their websites and what content they are interested in. This allows them to better adapt the content of the websites to the needs of their visitors, for example. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Location: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position of the respective device on Earth. Location data can be used, for example, to display map functions or other information dependent on a location.
  • Tracking: “Tracking” is when the behavior of users can be tracked across several online offerings. As a rule, behavioral and interest information is stored in cookies or on servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to match their interests.
  • Person in charge: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is far-reaching and encompasses practically any handling of data, be it collection, evaluation, storage, transmission or deletion.
  • Contract: Contract data is specific information related to the formalization of an agreement between two or more parties. They document the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and performance of contractual obligations and includes both the identification of the parties to the contract and the specific terms and conditions of the agreement. Contract Data may include the start and end dates of the contract, the type of services or products agreed upon, pricing agreements, payment terms, termination rights, renewal options, and any special terms or clauses. They serve as the legal basis for the relationship between the parties and are crucial for clarifying rights and obligations, enforcing claims and resolving disputes.
  • Payment: Payment data includes all the information needed to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking, and any other form of financial transaction. They include details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers, and billing information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.
  • Target group formation: Custom audiences are when target groups are determined for advertising purposes, e.g. the insertion of advertisements. For example, a user’s interest in certain products or topics on the Internet can be used to infer that this user is interested in advertisements for similar products or in the online shop in which they viewed the products. In turn, “lookalike audiences” (or similar target groups) are used when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are usually used for the purpose of creating Custom Audiences and Lookalike Audiences.